National Assembly for
Wales / Cynulliad Cenedlaethol Cymru
Health
and Social Care Committee /
Y Pwyllgor Iechyd a Gofal Cymdeithasol
Public Health
(Wales) Bill /
Bil Iechyd y
Cyhoedd (Cymru)
Evidence from Truckers
Toilets UK – PHB 64 / Tystiolaeth gan Truckers Toilets UK
– PHB 64
RESPONSE TO THE
CONSULTATION QUESTIONS
Relating to the
Public Health (Wales) Bill
September 2015
(Mrs) Gillian Kemp, MA
Public Toilets UK www.facebook.com/ptukcampaign
Truckers Toilets UK www.facebook.com/TTUKcampaign
Member, British Toilet Association
<www.britloos.co.uk>
Supporter, The IBS Network < www.theibsnetwork.org>
Email: XXXXXXXXXXXXXXXXXXXX
Part 6: Provision of Toilets:
What are your views on the proposal that each
local authority in Wales will be under a duty to prepare and
publish a local toilets strategy for its area?
- Good in theory. However whilst Section
93 (1) allows LAs the option of providing public toilets it does
not demand that they do so. Therefore the strategy could
result in not establishing public toilet facilities
(91,2,a).
- As 100% of the population needs a toilet
several times a day and Wales is a tourist hotspot, it would seem
vital that areas such as Gwynedd, where toilets are under threat,
should have toilet facilities available. Toilets encourage
tourism and enable people with urgency problems and disabilities to
leave their homes in the knowledge they can access a loo relatively
easily. This is in turn reduces mental health problems,
especially in older people who are often scared to go out in case
of an ‘accident’.
Do you believe that preparing a local toilet
strategy will ultimately lead to improved provision of public
toilets?
- Not necessarily. It could be read as a
‘paper’ exercise. Yes, it might give some LAs
encouragement to consider toilet provision but for those who are
looking for ways to reduce spending, toilet closures will continue
to be considered an easy option to save money in the short
term. Without the legal requirement to provide public toilets
there will be no pressure to make the necessary adjustments.
Communities and tourists will continue to suffer in the
meantime.
Do you believe the provision in the Bill to
ensure appropriate engagement with communities is sufficient to
guarantee the views of local people are taken into account in the
development of local toilet strategies?
- It’s a step in the right direction but
it is not a ‘guarantee’ that views will be taken into
account. This has been proved in other areas of the UK.
That said, there are some very active groups who have succeeded in
keeping their public toilets open and others groups who have
managed, by keeping up the pressure, to have toilets made
available.
- The term ‘appropriate engagement’
needs clear definition. There are some LAs who provide a tick
box document and call it a ‘consultation’. In
some instances the questions have been directed to the outcome
required with little or no opportunity for respondents to voice an
opinion.
- Consultations, if done properly, are a good
way of learning opinions but few LAs have the time or experience to
gather groups together to discuss the issues and summarise the
results. Consultations should include a wide range of people
/ organisations / businesses and anyone likely to be
affected.
Do you have any views on whether the Welsh
Ministers’ ability to issue guidance on the development of
strategies would lead to a more consistent approach across local
authorities?
- There may be a more consistent approach in
developing the strategies but it is the outcome for the various
communities which is the important issue. Guidance is always
useful. Someone with knowledge of the subject of the strategy
in question would be most appropriate.
What are your views on considering toilet
facilities within settings in receipt of public funding when
developing local strategies?
- Not clear what is being asked here. If
it means considering toilet facilities in publicly funded areas eg
council offices, museums, tourist information etc, then why
not? Toilets are a necessity for everyone.
- Many local authorities are closing public
toilets because their funds are being squeezed and they have
statutory obligations to provide certain services. Public
toilets are not part of that provision so if there are no means to
ensure public toilet availability, then having a toilet strategy
will be a waste of public money and time for many LAs who
don’t appreciate the need for public toilet
facilities.
- In order to develop a useful toilet strategy
LAs will need to understand the need for having public toilets
available.
Do you believe including changing facilities
for babies and for disabled people within the term
‘toilets’ is sufficient to ensure that the needs of all
groups are taken into account in the development of local toilet
strategies?
- Changing facilities for babies need to be
available to men and women and should be in a separate area to
general toilet facilities
- There are many types of disability.
Often forgotten are those with ‘hidden’ disabilities
such as IBS, those with a stoma, people taking certain types of
medication; those with bladder and/or bowel conditions etc who all
require space and clean facilities – often with a shelf - in
which to address their needs. Those in wheelchairs need to be
offered suitably sized and well designed surroundings whilst those
who have severe impairments should have access to Changing Places
facilities where hoists and adjustable height equipment is
available.
- Women’s needs are often forgotten: they
need somewhere hygienic to change sanitary pads / tampons when they
have their period and pregnant women need the loo more
frequently;
- British Standards BS6465 1-4 provides
information on sanitary installations and BS6465-4 in particular
relates to the Code of practice for the provision of public
toilets.
Do you believe the proposals relating to
toilet provision in the Bill will contribute to improving public
health in Wales?
- Having a strategy is good but if that
strategy is not implemented then it is time consuming in its
construction and worthless
- Access to a toilet is necessary for our
health – and safety. Research has shown that
‘urgency’ and ‘holding on’ can affect
concentration which is especially dangerous when driving.
‘Holding on’ can also cause serious health
problems. Lack of toilets encourages many people, including
drivers, to reduce their fluid intake to avoid the need for the
toilet. This can result in dehydration.
- Making toilets a legal requirement would
contribute to the sustainability of local communities; support the
growing 24 hour economy; encourage tourism; enable people to travel
and take up work opportunities; reduce infections; encourage good
hygienic practices; reduce incidents of fouling and improve public
health in Wales
-----oOo-----
Brief Biography
Gillian Kemp has been active in managing
charities but began her career in education and law and has also
worked in the media. She is the founder of Truckers’ Toilets
UK www.facebook.com/TTUKcampaign
and joint founder of Public Toilets UK www.facebook.com/PTUKcampaign
– both are campaigns which aim to improve toilet provision in
the UK. She has been involved with the British Toilet
Association [BTA] for a number of years and has given evidence on
behalf of The IBS Network on the effects of public toilet closures
to the Health & Social Care Committee at the Welsh
Assembly. On behalf of the BTA Gillian chaired a joint
venture with Hertfordshire Constabulary to revise a booklet on
reducing vandalism in publicly accessible toilets. She is
currently in the throes of editing another booklet on public toilet
facilities. Gillian is a Founder Director of an international
medical equipment manufacturing company